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2023 (6) TMI 400 - ITAT AMRITSARRevision u/s 263 - selection of the case under limited scrutiny - expansion scope of limited scrutiny - As per CIT high sea sales is speculative transaction and therefore disallowance of loss arising therefrom against the non speculative business income - HELD THAT:- As it is evident that the issue for which the PCIT issued the show cause notice was entirely different than the issues of selection of the case under limited scrutiny by the assessing officer. The Board in its circular mentioned the procedure for converting the limited scrutiny case into full-fledged scrutiny. From the perusal of the above said circular, it is abundantly clear that the conditions, which are sine qua non were non – existence, the AO did not have to make a request to convert a limited scrutiny case into full-fledged scrutiny. On similar facts, the coordinate bench, Amritsar in the case of Paradise Rubber Industries [2021 (10) TMI 444 - ITAT AMRITSAR] has held that revisionary jurisdiction shall not be invoked by the Pr. CIT to look into the issues which were not within the purview of limited scrutiny. AO cannot go beyond reasons for of limited scrutiny and thus, it would not be open to the PCIT to pass revisionary order u/s 263 on other aspects and remit matter to AO for fresh assessment. Assessee appeal allowed.
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